Order Execution and Counterparty Selection Policy (Professional) NN Investment Partners

Policy date November 2019

INFORMATION SHEET

Issued by: NN Investment Partners (hereafter ‘NN IP’) 1

Target audience: All employees of NN Investment Partners (legally represented by NN Investment Partners Holdings N.V.). Professional clients of ( of) NN Investment Partners Holdings N.V.2

For further information: Compliance E: [email protected] T: + 31 (0) 70 37 81236

Valid from: November 2019

Approval: NN Investment Partners’ Trading Review Committee, as delegated by the Management Team of NN Investment Partners, approved this policy on September 2019.

In the event of any discrepancies between the English version of this document and a translated version, the English document is binding.

1 NN Investment Partners includes (but is not limited to) the entities NN Investment Partners Holdings N.V., NN Investment Partners International Holdings B.V., NN Investment Partners B.V. (including branches), NN Investment Partners B.V., NNIP Advisors B.V. (including branches), NN Investment Partners Luxembourg S.A. (including branches), NN Investment Partners North America LLC, NN Investment Partners Belgium S.A., NN Investment Partners () Ltd and NN Investment Partners (Japan) Co., Ltd., NN Investment Partners Towarzystwo Funduszy Inwestycyjnych S.A., NN Investment Partners C.R., a.s., and Altis Investment Management A.G. 2 Professional clients include (but are not limited to) all investment funds managed by NN Investment Partners B.V., NN Investment Partners Advisors B.V., NN Investment Partners Luxembourg S.A. , NN Investment Partners Belgium S.A., NN Investment Partners North America LLC, NN Investment Partners (Singapore) Ltd, NN Investment Partners (Japan) Co., Ltd. and NN Investment Partners Towarzystwo Funduszy Inwestycyjnych S.A.

NN IP Order Execution and Broker Selection Policy (Professional) Page 2 of 9

TABLE OF CONTENT

1. INTRODUCTION ...... 4

2. OBJECTIVES AND SCOPE ...... 4

4. DELEGATION ...... 5

5. APPROVED BROKER AND EXECUTION VENUE LIST ...... 5

6. BROKER AND EXECUTION VENUE EVALUATION AND SELECTION ...... 5

7. ORDER EXECUTION PER ASSET CLASS / INSTRUMENT TYPE ...... 7

8. MONITORING QUALITY OF EXECUTION ...... 8

9. SPECIFIC INSTRUCTIONS and OTHER EXCEPTIONS ...... 9

10. MONITORING AND REVIEW OF THE POLICY ...... 9

ANNEX I – List of Brokers and Execution Venues

NN IP Order Execution and Broker Selection Policy (Professional) Page 3 of 9

1. INTRODUCTION

NN Investment Partners (hereafter ‘NN IP’) invests in a broad range of financial instruments, such as equities, bonds, foreign exchange, futures, options, swaps (these are the most commonly traded instruments). In light of this activity NN IP carries out client order executions. NN IP has a duty to ensure that it obtains the best possible result for its clients.

For the transposition of these duties, NN IP deems the interests of clients best served with a transparent view on the selection of Brokers and Execution Venues (Regulated Markets, Multilateral Trading Facilities (MTF) and Organised Trading Facility (OTF), a Systematic Internaliser (SI), or a market maker or other liquidity provider or an entity that performs a similar function in a third country to the functions performed by any of the foregoing when trading in financial instruments. This policy summarizes NN IP’s process for taking all sufficient steps when transmitting or carrying out client order executions such as: • Broker and Execution Venue evaluation and selection • The relative importance of execution criteria and how these are incorporated in the process • NN IP’s approach to transmit and execute client orders per asset class • How NN IP monitors order transmission or execution and how NN IP monitors its execution policy.

2. OBJECTIVES AND SCOPE

The objective of this Policy is to establish and describe the process for execution and order handling within NN IP. This Policy will be available to NN IP’s clients to provide transparency on NN IP’s policy to take sufficient steps to obtain the best possible result for its clients and as required by applicable law. This Policy also describes the client order execution process in relation to financial instruments, amongst others within the meaning of Annex 1 Section C to MiFID3 , UCITS4 and AIFMD5 as transposed in national legislation.

The Policy applies to the relationship between NN IP and any professional client (within the meaning of the Markets in Financial Instruments Directive (MiFID), UCITS and AIFMD, as transposed in national legislation).

3. ACTIVITIES

NN IP assesses Brokers and Execution Venues to determine whether they are able to provide, on a consistent basis, order execution on terms most favourable to NN IPs clients. This policy will apply when: (1) NN IP is providing discretionary portfolio management services; or (2) NN IP is providing solely order execution services. In both scenarios, NNIP can execute itself or (receive and) place an order with another entity for execution. NN IP may place orders with Brokers (that may or may not be execution venues) in the EEA who themselves will be subject to MiFID execution requirements. NN IP has given explicit authorisation to these Brokers to carry out the execution of its orders outside a Regulated Market, MTF or OTF. Execution of orders outside a Regulated Market can generate an enhanced counterparty risk. NN IP may transmit orders to Brokers outside the European Economic Area (EEA).

NN IP may execute via an Execution Venue and may also engage in Over The Counter (OTC) trading. NN IP can execute its orders outside Regulated Market, MTF or OTF. Execution of orders outside a Regulated Market, MTF, OTF or traded OTC can generate an enhanced counterparty and or settlement risk. NN IP may execute orders with Execution Venues outside the EEA.

3 European Union Directive 2014/65/EC on Markets in Financial Instruments 4 European Union Directive 2014/91/EU on t undertakings for collective investment in transferable securities (UCITS) 5 European Union Directive 2011/61/EU on Fund Managers

NN IP Order Execution and Broker Selection Policy (Professional) Page 4 of 9

In Annex I (the ‘Annex’), a list of Broker and Execution Venues is available. The majority of the trades will be executed via the Brokers and Execution Venues listed in the Annex. The Annex will be updated regularly to reflect amendments to the list.

4. DELEGATION

NN IP believes that execution quality can best be serviced by having execution capabilities in 3 regions, Asia, Europe and US. As such NN IP might delegate execution to our internal Traders within an affiliate entity in any region.

Where NN IP delegates execution of trades to an affiliated or a non-affiliated entity it will ensure that such delegation is permitted in the contractual arrangements with the client. Any such delegation may be subject to the rules of a regulator in the jurisdiction of the delegate (including a jurisdiction outside the EEA) and not be subject to the ESMA rules and may not be required to maintain an order execution policy. In such circumstances NN IP has the duty to ensure that the service provided to its client is performed in accordance with the best interests of the client. NN IP also has the duty to ensure that its selection of the delegate and overall management of the portfolio continues to meet this obligation. Further NN IP ensures that any such delegation shall be governed by terms of a service provider agreement between NN IP and the delegate, by virtue of which the delegate will be responsible to NN IP for the performance of its obligations.

5. APPROVED BROKER AND EXECUTION VENUE LIST

Client transactions may be executed only with or through Broker and Execution Venues that meet prescribed minimum requirements applied by NN IP. A detailed Broker and Execution Venue approval process is described in the credit risk policy. The approval process involves amongst others Trading, Credit Risk Management, Compliance and NN IP’s Legal department.

Exceptions In exceptional circumstances, NN IP may use a Broker or Execution Venue which is currently not listed in this policy (e.g., in case a Broker or Execution Venue can provide necessary liquidity in a certain instrument, to accommodate execution in an unusual instrument or a new issue). This is permitted when in line with NN IP’s relevant policies and procedures.

6. BROKER AND EXECUTION VENUE EVALUATION AND SELECTION

NN IP has the duty to provide best possible results for clients. This duty is not limited to solely obtaining the best price, speed, liquidity and/or costs. NN IP may also consider the full range of an executing Broker’s or Execution Venue’s services, including but not limited to execution capabilities, likelihood of execution, quality of execution, speed and likelihood of settlement, financial responsibility, size and nature of the order, risk management considerations and responsiveness to enhance the overall value of client accounts related to order execution for both short term and long term. To this end NN IP views that its clients are best serviced with a two tiered approach; 1. Periodical evaluation and selection of an execution panel with Brokers and Execution Venues according to execution criteria and the relative importance of these criteria 2. On continuous basis when executing client orders NN IP takes into account execution criteria and their relative importance

To assess the ability of a Broker and Execution Venue to provide the best possible result for NN IP’s client, a set of criteria is being used. The relative importance of these criteria are listed below in order of importance, however some criteria might outweigh in certain asset classes (or instrument types). The weighting of these criteria can also differ across asset classes (instrument types) and NN IP will implement an evaluation-model per asset class. This model will result in an execution panel of Brokers and Execution Venues for each asset class.

NN IP Order Execution and Broker Selection Policy (Professional) Page 5 of 9

Criteria to add Brokers or Execution Venues to the execution panel of an asset class and or instruments types can be:

1) General execution capabilities of Brokers and Execution Venues: a) the quality and effectiveness of a Broker’s or Execution Venue’s execution policy, in order for a Broker or Execution Venue to reach the best possible result for NN IP’s client including breadth and depth of market access, connectivity to platforms and or access to specific markets. b) the Broker’s or Execution Venue’s evaluation capabilities (pre and post trade) and the timely and accurate provision of execution reports. c) the Broker’s or Execution Venue’s ability to adhere to the waivers and deferrals as further defined by relevant regulators. d) the Broker’s or Execution Venue’s regulatory regime and status.

2) Trade analysis such as Transaction Cost Analysis (TCA): a) the Broker’s or Execution Venue’s ability to provide the best price and/or competitiveness of all expenses incurred for the transaction, such as commission rates. b) the Broker’s or Execution Venue’s ability to commit adequate capital when necessary. c) the Broker’s or Execution Venue’s ability to search for and obtain liquidity to minimize market impact and accommodate unusual market conditions and Execution Venue’s ability to maintain the confidentiality of an order and prevent information leakage. d) quality, offering, speed of electronic execution methods and program trading (ability to execute multiple transactions). e) efficiency and accuracy of the Broker’s or Execution Venue’s clearance and settlement process, including splits across clients. f) the level of efforts exercised by the Broker or Execution Venue, to satisfy trading needs in a consistent manner and a proven track-record of the Broker or Execution Venue.

3) Qualitative: a) flexibility: is the Broker or Execution Venue able to execute unique trading strategies/execute and settle difficult trades as well as unusual trading volumes. b) the level to which the Broker or Execution Venue is responsive to comments or to complaints from NN IP. c) the Broker’s or Execution Venue’s ability to engage in after-hours and cross-border trading. d) availability and quality of Execution Venue’s Traders and sales-Traders etc.. e) Brokers or Execution Venues are expected to behave in an ethical and professional manner to promote the fairness and integrity of the markets they are active in, supported by acceptance of codes of conduct when relevant. f) response time and adequate lines of communication with Broker’s or Execution Venue’s staff and NN IP. g) a Brokers or Execution Venue’s ability to anticipate on, adopt and have access to alternative trading options with a view on achieving higher quality execution. h) Risk management: limit observation and Execution Venue diversification considerations.

4) other factor(s) NN IP deems relevant in selection of a Broker or Execution Venue.

Brokers and Execution Venues listed on NN IP’s execution panels will be deemed to be able to obtain the best possible result for NN IP’s clients. NN IP can decide to execute with a Broker or Execution Venues which are not on NN IP’s execution panels, to obtain the best possible result. This is permitted as long as this is in line NN IP’s relevant policies.

The Brokers and Execution Venues will be formally reviewed on a semi-annual basis. In this review, any of the criteria above can be rated. Governance of this process will be with the TRC. The evaluation process and outcome is documented and maintained by NN IP for at least ten years.

NN IP Order Execution and Broker Selection Policy (Professional) Page 6 of 9

7. ORDER EXECUTION PER ASSET CLASS / INSTRUMENT TYPE 6

When selecting a Broker or Execution Venue and choosing the method of trading for executing an order, the main factors that are taken into account are price, speed, likelihood of execution and settlement, explicit cost, market impact and liquidity The relative importance of these factors will alter for each trade depending on market circumstances, instrument specific considerations, portfolio objectives, Traders' and Portfolio Managers' assessment of the market, size and nature of the order, the risk appetite of Execution Venues and availability of inventory. Price and costs usually are the most important factors, when selecting a Broker or Execution Venue. For certain transactions it may not always be possible or appropriate to request comparable price information from Execution Venues. Approaching multiple venues or Execution Venues for a competing quote is likely to have a negative effect on a transaction because of possible information leakage. Execution Venues can be specialised in the specific instrument, specific market, have inventory or have special abilities in these products or markets. On a daily basis there is intensive contact between the Execution Venues and NN IP about market developments, flows or special demand or offers in the different markets. Certain designated orders can be auto-routed to brokers or execution venues based on the execution panels. There is a clear approval process and governance in case orders will be auto-routed to brokers or execution venues. Orders can only be auto-routed after sufficient testing and when there is sufficient oversight.

Listed derivatives Orders in listed derivatives can be executed by: (1) Transmitting orders to NN IPs Brokers for further order handling (2) By using algorithmic facilities provided by Brokers (3) NN IP directly with an Execution Venue, on an MTF or OTF, depending on the size and the instrument. The execution fees will be taken into consideration when choosing a method, as they may differ.

Equities Orders in equity instruments can be executed by: (1) Transmitting orders to NN IPs Brokers for further order handling (2) By using algorithmic facilities provided by Brokers (3) NN IP directly with an Execution Venue, outside a regulated markets, on an MTF or OTF, depending on the size and the instrument.

Depending on the size, market circumstances, number of transactions and stock specific news, NN IP will use its own judgment and experience in determining which execution method it will use. Each of the execution methods might have different commission rates charged by Brokers; higher rates may justify favourable pricing and access to liquidity, lower rates are usually charged in case of highly efficient trading methods such as algorithmic trading or program trading. The execution fees will be taken into consideration when choosing a method, as they may differ.

Exchange traded mutual funds There are different ways of executing listed mutual funds: - Orders in exchange traded mutual funds can be transmitted for execution to our Brokers. - NN IP may conclude transactions in listed mutual funds with the fund provider at official prices, because NN IP may believe that there is no sufficient liquidity available on other Execution Venues. - NN IP also engages in executing orders on MTFs or OTFs. The transaction costs charged by the Brokers and Execution Venues for these methods may differ. Execution of the order can be done outside a regulated market or MTF or OTF.

Fixed Income

6 Reference is made to Annex 1 of RTS 28 supplementing Directive 2014/65/EU

NN IP Order Execution and Broker Selection Policy (Professional) Page 7 of 9

A relatively large part of the instruments that are traded may have limited price transparency, or may only to a limited extent be available in the market. Depending on the transparency of pricing and the perceived liquidity of the instruments the orders may be placed in competition. Some larger size bond orders and orders in illiquid bonds or illiquid markets may be executed through bilateral negotiations with one Execution Venue. Orders can also be transmitted for execution to NN IP’s Brokers. Execution of the order can be done outside a regulated market or MTF or OTF.

Bilateral OTC derivatives (incl Foreign Exchange) In pursuing the best possible result for its clients, NN IP will take the criteria mentioned above into account and additionally will take into account other criteria such as quality and negotiability of the legal documentation and agreements with the Execution Venues, including any risk criteria. Transactions in these instruments can only be carried out with Execution Venues which have legal documentation and agreements set-up (ISDA/CSA or comparable) and signed with NN IP. Depending on the transparency of pricing and the perceived liquidity of the instruments the orders may be placed in competition. Spot FX can be executed without above mentioned documentation. NN IP accepts the FX Global Code, a set of global principles of good practice in the foreign exchange market. Foreign Exchange: In some specific cases, mostly when NN IP executes securities in instruments that denominate in Non- Deliverable Currencies, or in case of share-class hedging NN IP relies on custodians for execution.. For the avoidance of doubt, NN IP shall not employ ‘best execution’ or actively negotiate rates with regard to those indirect FX transactions which are undertaken for clients by third parties such as the clients’ custodian. NN IP will actively negotiate fees Execution of the order can be done outside a regulated market or MTF or OTF.

Cleared OTC derivatives For Cleared OTC derivatives NN IP takes into account the MiFID trading obligation, the clearing agreements, clearing limits and CDEA’s (Counterparty Derivatives Execution Agreements). NN IP works with multiple clearing brokers and the costs of clearing and execution can differ. Execution of the order can be done outside a regulated market or MTF or OTF when permitted by the trading obligation requirement.

Deposits Generally, NN IP is an active manager, with portfolios that are typically fully invested with minimal residual cash balances maintained at the client’s custodian. However in case there is excess cash, and when cash is placed on deposit away from the custodian, NN IP will only use from the list for approved deposits banks.

Crossing and aggregation Crossing a transaction with an external provider, Broker or Execution Venue is possible where permitted by guidelines, applicable laws and regulations and pursuant to the Cross Trade procedures or local equivalent. Costs can be charged by the Broker or other service provider involved in the process. These trades can be done outside a regulated market or MTF or OTF. In addition, the Trader can aggregate orders provided such aggregation is in accordance with the requirements Trade Aggregation and Allocation requirements as set by NN IP.

NN IP may also work with limits, contingent orders or specific other instructions if NN IP considers this to be in the interest of its clients.

8. MONITORING QUALITY OF EXECUTION

Within NN IP a process is implemented to monitor execution quality. In this process Traders monitor on a continuous basis execution of all orders. Governance of daily monitoring of executions lies with the Head of Trading. Next to that Compliance performs monthly reviews to the level of adherence to the various NN IP trading policies, including this Policy. The process varies per asset type and/or instrument type taking into account the (market-) information available per asset

NN IP Order Execution and Broker Selection Policy (Professional) Page 8 of 9

class. The monitoring will, inter alia, be aimed at assessing the execution quality of the Brokers and Execution Venues selected pursuant to this Policy, as follows from the evaluation of Brokers and Execution Venues in accordance with the evaluation process described above, as well as NN IP’s own ability to reach the best possible result for its clients when executing transactions. The TRC has oversight and supervision of the Brokers and Execution Venue evaluation and selection process. NN IP’s TRC is comprised of senior management and second line. It meets on a regular basis and reviews execution reports, commissions, Brokers, Execution Venues, the Execution Venue evaluation process and outcome and internal trading issues and controls. The results of ongoing execution monitoring are escalated to this committee.

In addition, MiFID II (RTS 28) requires that investment firms, as part of their best execution obligations, report their top five venues for all trading on behalf of clients. NN IP publishes these reports on its website.

9. SPECIFIC INSTRUCTIONS and OTHER EXCEPTIONS

Client specific instruction regarding use of Execution Venues (including directed brokerage) NN IP generally does not act on the basis of specific client instructions to place trades through a specific Execution Venue or execute specific instructions (limit-orders are accepted). However, where the relationship with its clients so permits and to the extent that NN IP can act on clients’ specific instructions without harming or causing disadvantage to other NN IP’s clients, it may act on specific instructions.

Clients should be aware that this policy may not apply in case client provides NN IP with specific order instructions and that these specific instructions may prevent NN IP from taking the steps set out in this Policy. NN IP still aims to obtain the best possible result in respect of the elements covered by those instructions.

Other exceptions In addition, this policy will generally not apply to transactions with respect to highly customised financial products which are tailored to specific circumstances of a client and its account, or if a transaction, executed by NN IP itself, involves a financial instrument relating to one particular Broker or Execution Venue only.

Furthermore, the duty of obtaining the best possible result for NN IP’s clients can also be met where NN IP makes use of a facilitating Broker. If the trades are executed through this Agent Broker, they will show in NN IP’s files as done with one Broker, but are actually performed with a variety of Execution Venues of that Agent Broker, in accordance with the principles of this Policy.

Non-listed Mutual Funds Subscription, redemption and conversion transactions relating to units in UCITS, UCIs or other Collective Investment Vehicles are routed to the relevant funds’ transfer agent and executed based on net asset value (NAV), taking into account potential swing-pricing or premiums/ discounts, as described in the relevant fund documentation. NN IP considers subscription, redemption or conversion of UCI shares or units executed based on the NAV as fulfilling execution criteria.

10. MONITORING AND REVIEW OF THE POLICY

Identifying deficiencies of the Policy The effectiveness and accuracy of this Policy, acting in accordance with it and the principles and procedures contained in it will be monitored on a continuing basis by multiple parties, including the TRC, Risk Management, Compliance and Global Trading. In addition, where NN IP identifies shortcomings in its, or its Broker’s or Execution Venue’s abilities to obtain the best possible result for its clients, such deficiencies will be detected and addressed appropriately in a revision of this Policy.

NN IP Order Execution and Broker Selection Policy (Professional) Page 9 of 9

ANNEX I - List of Brokers and Execution Venues as per 05-04-2019 1 Listed Securities Listed Securities ABG Sundal Collier Norge ASA BPCE SA ABN AMRO NV BRD-Groupe Societe Generale SA Advanced Capital Securities Uruguay Agente de Valores BRED Banque Populaire AFS Group B.V. BT Securities SA Ak Yatirim Menkul Degerler A.S. BTG Pactual US Capital LLC Alpha Finance Romania SA Canaccord Genuity Inc Arqaam Capital Limited Cantor Fitzgerald Europe Aust and NZ Banking Group LTD Cantor Fitzgerald LP Australia and New Zealand Banking Group Ltd, Melbourne branch Carnegie Ltd Australia and New Zealand Banking Group Ltd, Singapore branch Ceska Sporitelna, A.S. Autonomous Research Ltd Ceskoslovenská obchodná banka Banca Comerciala Romana SA Ceskoslovenska obchodni banka AS Banca de Export-Import a României EximBank - S.A China International Capital Corp Banca IMI Spa CIBC World Markets Corp Banco Bilbao Vizcaya Argentaria SA, New York branch Citadel Securities (Europe) Ltd Banco Itau SA Citibank Colombia SA SA Citibank Europe PLC Banco Santander SA, branch Citibank Europe Plc, Magyarorszagi Fioktelepe Banco Santander SA, New York branch Citibank Europe PLC, Romania branch Bank at Bellevue Ltd Citibank Korea Inc Bank Audi Sal - Audi Citibank NA Bank BGZ BNP Paribas SA Citibank NA, London branch Bank Handlowy w Warszawie SA Citic Securities Brokerage HK Bank of America Lynch International Bank Designated Activity Company Global Markets Europe AG Bank of America NA Citigroup Global Markets Inc Bank of America NA, London branch Citigroup Global Markets Korea Securities ltd Bank of America Securities Ltd Citigroup Global Markets Ltd Bank of China International Securities Ltd (BOCI Securities Ltd) CLSA (UK) Bank Polska Kasa Opieki SA Commerz Markets LLC BANQUE DE LUXEMBOURG S.A. Commerzbank AG Barclays Bank Ireland Public Limited Company Commerzbank AG, London branch Barclays Bank PLC Commerzbank AG, Luxembourg branch Barclays Bank PLC, branch COMMONWEALTH BANK OF AUSTRALIA Barclays Capital Inc - The Division of Barclays Bank PLC Coöperatieve U.A. Bayerische Hypo- und Vereinsbank AG Copernicus Securities SA Bayerische Landesbank Cowen & Co LLC BBVA Colombia Credit Agricole CIB UK IH BBVA Securities inc Credit Agricole SA Belfius Bank SA/NV Credit Agricole USA Inc BFCM (Banque Federative du Credit Mutuel) AG BFCM, am Main branch Credit Suisse International BGC Financial, L.P Credit Suisse Securities (Europe) Ltd BH Securities AS Credit Suisse Securities (USA) LLC BlackRock Advisors (UK) Limited Credit Suisse Securities, Sociedad de Valores, S.A. Bloomberg Tradebook Europe Ltd Daiwa Capital Markets Deutschland GmbH BMO Capital Markets Corp Daiwa Capital Markets Europe Ltd BMO Nesbitt Burns Ltd Danske Bank A/S BNP Paribas Colombia Corporacion Financiera DB Securities S.A. BNP Paribas SA DBS Bank Ltd BNP Paribas SA - Warszawa branch DBS Bank Ltd, Hong Kong branch BNP Paribas SA, London branch Delta Lloyd Bank NL BNP Paribas SA, New York branch AG BNP Paribas SA, Paris branch Deutsche Bank AG, London branch BNP Paribas SA, Seoul branch Deutsche Bank AG, Seoul branch BNP Paribas SA, Singapore branch Deutsche Bank AG, Singapore branch BNP Paribas SA, Taipei branch Deutsche Bank Polska BNP Paribas Securities (Asia) Ltd Deutsche Bank Securities Inc BofA Securities Europe SA Deutsche Bank Zrt

1 Listed Financial Instruments can include Equities (shares and depositary receipts), Debt Instruments, Interest rates derivatives, Equity derivatives, Derivatives, Currency derivatives, Warrants and Certificate derivatives. Bilateral OTC Derivatives include Interest Rate derivatives, Credit derivatives, Total return derivatives, Commodities derivatives, Equity derivatives, Currency derivatives, Warrants and Certificate derivatives

Page 1 of 4

Listed Securities Listed Securities DM PKO Banku Polskiego SA Jane Street Financial Limited Dom Maklerski Banku Handlowego S.A. Janney montgomery Scott LLC Dom Maklerski Banku Ochrony Srodowiska SA Jefferies GmbH Dom Maklerski BZWBK S.A. Inc DSK Bank PLC Jefferies International Ltd DZ Bank AG Deutsche Zentral-Genossenschaftsbank Jefferies International Ltd, Singapore Branch EFG Eurobank Securities SA Joh. Berenberg, Gossler & Co KG Erste Bank Hungary Nyrt JP Morgan Chase Bank NA, London branch Erste Group Bank AG JP Morgan Chase Bank NA, Seoul branch Erste Securities Polska SA JP Morgan Chase Bank NA, Singapore branch Exane SA JPMorgan Chase Bank NA Exotix Partners LLP JPMorgan Chase Bank NA, Singapore branch FHB Commercial Bank Ltd JPMorgan Colombia Ltda. Freimark Blair & Co Inc JPMorgan Securities Plc GMP Securities, LLC Kas Bank N.V. & Co KBC Bank NV Goldman Sachs AG KBC Securities Oddzial w Polsce Goldman Sachs International Ltd Kempen & Co NV Goldman Sachs Mitsui Marine Products LP Kepler Capital Markets SA Goodbody Stockbrokers Knight Capital Europe Ltd Green Street Advisors, Inc Komercni Banka AS Greenstreet Advisors (UK) Ltd Landesbank Baden-Württemberg Guggenheim Securities LLC LarrainVial S.A. Corredora de Bolsa Haitong Bank SA, Warsaw branch Libra Internet Bank Romania Hapoalim Securities USA, Inc Liquidity Finance LLP Helvea Ltd Liquidnet EU Limited HSBC Bank PLC Liquidnet Europe Limited HSBC Bank Plc, Prague branch Liquidnet Holding Inc HSBC Bank Polska SA Lloyds Bank Corporate Markets PLC HSBC Bank USA NA Macquarie Bank Ltd HSBC France S.A. Macquarie Capital (USA) Inc HSBC Trinkaus Burkhardt AG Macquarie Capital Securites Ltd ICAP Corporate LLC Macquarie Equities Ltd ICAP Securities Ltd Mariva Capital Markets LLC ICBC PLC (London) MarketAxess Capital Limited IEBA Trust SA MarketAxess Corp Imperial Capital LLC mBank SA ING Bank N.V. Sucursala Bucuresti Merrill Lynch International ING Bank N.V. Hungary Branch Merrill Lynch International Inc, Seoul branch ING Bank N.V., Manila Branch Merrill Lynch Pierce Fenner & Smith Inc ING Bank N.V., pobocka zahranicnej banky Millennium Advisors LLC ING Bank N.V., Prague branch Millennium Dom Maklerski S.A. ING Bank N.V., Seoul branch Millennium Europe Ltd ING Bank N.V., Singapore branch Mirabaud Securities Ltd ING Bank NV Mitsubishi UFJ Securities (USA) inc ING Bank Slaski Spolka Akcyjna Mizuho International Plc ING Belgium SA/NV USA inc ING Luxembourg SA MONETA Money Bank, a.s. Instinet Europe Ltd & Co International PLC Bank Ltd Morgan Stanley & Co. LLC Investment Technology Group Ltd Morgan Stanley Europe SE Ipopema Securities SA Morgan Stanley London branch Is Yatirim Menkul Degerler A.S. MUFG Securites EMEA PLC ITG Europe Ltd MUFG Securites EMEA PLC, Singapore Branch J & E Davy MUFG Securities (Europe) N.V. J & T Banka AS MUFG Securities Asia (Singapore) Ltd J.P. Morgan AG MUFG Securities EMEA PLC J.P. Morgan Markets Ltd National Australia Bank Ltd

NN IP Order Execution and Broker Selection Policy (Professional) – Annex 1 Page 2 of 4

Listed Securities Listed Securities National Bank of Canada Financial Inc Bank Nationale-Nederlanden Bank N.V. Standard Chartered Bank (Hong Kong) Ltd S.A. Standard Chartered Bank, New York branch Natixis Securites Americas LLC Standard New York, Inc NatWest Markets N.V. State Street Bank and Trust Company Navigator Capital S.A. State Street Global markets LLC NIBC Bank NV Nicolaus & Co Inc Nomura Financial Products Europe GmbH Stifel Nicolaus Europe Ltd Nomura International PLC Stuart Frankel & Co., Incorporated International Inc SumRidge Partners LLC Norddeutsche Landesbank Girozentrale Suntrust Robinson Humphrey Inc Nordea Bank Finland Svenska Handelsbanken Nordea Bank Norge ASA Swiss Capital S.A. ODDO BHF SCA Tatra banka, a.s. Odeon Capital Group LLC TD Securities ltd Oolders Heijning and Voogelaar B.V. The Bank of New York Mellon Oppenheimer & Co Inc The Bank of New York Mellon, London branch Oppenheimer EU Limited The Hongkong and Banking Corporation Ltd OTP Bank Nyrt The Hongkong and Shanghai Banking Corporation Ltd, London branch OTP Bank Romania SA The Hongkong and Shanghai Banking Corporation Ltd, Seoul branch Oversea-Chinese Banking Corporation Limited TPCG Agente de Valores SA Peel Hunt LLC Tradeweb Direct, LLC Pekao Investment Banking SA Trigon Dom Maklerski SA Pekao Investment Banking Spolka Akcyjna Tullett Prebon Securities Ltd Petercam SA/NV UBS AG Piraeus Securities SA UBS AG, Hong Kong branch PKO Bank Polski SA UBS AG, London branch PPF Banka AS UBS AG, Stamford branch Raiffeisen Bank International AG UBS Europe SE Raiffeisen Bank Polska UBS Securities Pte Ltd, Seoul branch Raiffeisen Bank SA Bank AG Raiffeisen Centrobank AG UniCredit Bank AG Vienna branch Raymond James & Associates Inc UniCredit Bank Czech Republic and Slovakia as RBC Capital Markets (Europe) GmbH UniCredit Bank Hungary RBC Capital Markets Corp UniCredit Bank SA Romania RBC Europe Ltd Unicredit Bulbank AD Renaissance Capital Ltd UniCredit SpA, London branch RGA Americas Reins Comp Limited RGA Global Reinsurance Comp Ltd United Overseas Bank Ltd Robert W & Co Inc US Bancorp Investments Inc Vseobecna Uverova Banka AS RW Pressprich & Co VTB Bank (Europe) SE Samsung Securities Co. Ltd VTB Capital PLC Sanford C Bernstein Proprietary Ltd Securities International Ltd Sanford C Berstein Co Inc Wells Fargo Securities LLC Santander Bank Polska Spolka Akcyjna WESTPAC Europe Ltd Sberbank CIB (UK) Ltd Wood & Company Financial Services A/S SC Lowy Financial (HK) Ltd Scotia Capital (USA) Inc MTFs Seaport global securities LLC Bloomberg MTF (BTFL) Shinkin International LTD. Bloomberg MTF (BTFE) Skandinaviska Enskilda Banken AB (Publ) FXAll Slovenska Sporitelna AS Market Axess SMBC Nikko Capital Markets Ltd Market Axess (EU) SNS securities N.V. MTS (UK) Societe Generale Expressbank AD MTS Spa Societe Generale SA Tradeweb EU Societe Generale, Warszawa Branch Tradeweb (UK)

NN IP Order Execution and Broker Selection Policy (Professional) – Annex 1 Page 3 of 4

Listed Derivatives Clearing (some client specific exceptions possible) Bilateral OTC Derivatives JPMorgan Securities Plc Citibank NA Morgan Stanley & Co International PLC Citibank NA, London branch Citigroup Global Markets Europe AG Citigroup Global Markets Ltd OTC Clearing (some client specific exceptions possible) Commerzbank AG BNP Paribas SA Coöperatieve Rabobank U.A. Citigroup Global Markets Ltd Credit Suisse AG Deutsche Bank AG Credit Suisse International JPMorgan Securities Plc Delta Lloyd Bank NL Merrill Lynch International Deutsche Bank AG Societe Generale Deutsche Bank AG, London branch Deutsche Bank AG, Singapore branch Goldman Sachs AG Execution of cleared OTC Derivatives Goldman Sachs International Ltd Barclays Bank PLC Goldman Sachs Mitsui Marine Derivative Products LP Banco Santander SA Hannover Re Bank of America N.A. HSBC Bank PLC BNP Paribas HSBC Bank USA NA Citigroup Global Markets Ltd HSBC France S.A. Citigroup N.A. ING Bank N.V. Hungary Branch Deutsche Bank AG ING Bank N.V., pobocka zahranicnej banky ING Bank NV ING Bank N.V., Prague branch JP Morgan Sercurities PLC ING Bank NV JP Morgan N.A. ING Bank Slaski Spolka Akcyjna Goldman Sachs International ING Belgium SA/NV HSBC Bank PLC ING Luxembourg SA Merrill Lynch International J.P. Morgan AG Morgan Stanley & Co International PLC JP Morgan Chase Bank NA, London branch Nomura International PLC JP Morgan Chase Bank NA, Singapore branch Societe Generale JPMorgan Chase Bank NA The Royal Bank of Canada JPMorgan Chase Bank NA, Singapore branch The JPMorgan Securities Plc Kas Bank N.V. Merrill Lynch International

Third Parties (some client specific exceptions possible) Morgan Stanley & Co International PLC NN Investment Partners North America LLC Morgan Stanley Europe SE NN Investment Partners (Singapore) Ltd. Morgan Stanley London branch Bank of New York Natixis S.A. NN Re (Netherlands) NV State Street NN Interfinance B.V. Nomura Financial Products Europe GmbH

Bilateral OTC Derivatives Nomura International PLC ABN AMRO Bank NV RGA Americas Reins Comp Banco Santander SA RGA Global Reinsurance Comp Ltd

Bank of America NA Royal Bank of Canada

Bank of America NA, London branch Slovenska Sporitelna AS

Banque de Luxembourg S.A. Societe Generale Expressbank AD

Barclays Bank Ireland Public Limited Company Societe Generale SA

Barclays Bank PLC The Bank of New York Mellon BlackRock Advisors (UK) Limited The Bank of New York Mellon, London branch BNP Paribas SA UBS AG BofA Securities Europe SA UBS AG, Hong Kong branch Ceska Sporitelna, A.S. UBS AG, London branch Citadel Securities (Europe) Ltd Unicredit Bulbank AD Citibank Europe PLC, Romania branch Vseobecna Uverova Banka AS

NN IP Order Execution and Broker Selection Policy (Professional) – Annex 1 Page 4 of 4